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ITALIN GROUP CODE OF CONDUCT

We are committed to maintaining the business’s ethical, moral, and safe standards. We work hard to maintain the growth and development of a workplace where these standards are the foundation of our operations.

ITALIN GROUP CORPORATE RESPONSIBILITY POLICY

Italin Group (“Company”) employees will maintain the highest ethical standards in the conduct of Company affairs. Intent of this policy is that each employee will conduct the Company’s business with integrity and comply with all applicable laws in a manner that excludes considerations of personal advantage or gain. General Policy Application:

CONFLICTS OF INTEREST

Employees should avoid any situation which involves or may involve a conflict between their personal interest and the interest of the Company. As in all other facets of their duties, employees dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with the Company are to act in the best interest of the Company. Each employee shall make prompt and full disclosure in writing to their manager of any potential situation which may involve a conflict of interest.

SUCH CONFLICTS INCLUDE:

Ownership by employee or by a member of their family of a significant interest in any outside enterprise which does or seeks to do business with or is a competitor of the company.
Serving as a director, officer, partner, consultant, or in a managerial or technical capacity with an outside enterprise which does or is seeking to do business with or is a competitor of the company.
Acting as a broker, finder, go-between or otherwise for the benefit of a third party in transactions involving or potentially involving the Company or its interests.
Any other arrangements or circumstances, including family or other personal relationships, which might dissuade the employee from acting in the best interest of the Company.

CONFIDENTIAL INFORMATION

The revelation or use of any confidential product information, data on decisions, plans, or any other information which might be contrary to the interest of the Company without prior authorization, is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, particularly personnel information, is strictly prohibited and will subject an employee to disciplinary action up to and including immediate discharge.

COMPLIANCE

Any violation of this policy will subject the employee to disciplinary action or immediate discharge. Any Company employee having knowledge of any violation of the policy shall promptly report such violation to the appropriate level of management.

PROTECTION OF COMPANY ASSETS

COMPUTER SOFTWARE LICENSING

The Company purchases or licenses the use of various computer software programs. Neither the Company nor any of the Company’s employees has the right to duplicate this computer software or its related documentation. Unauthorized duplication of computer software is a federal offense, punishable by up to a $250,000 fine and up to five years in jail.
The Company does not condone the illegal duplication of software. You must use the software in accordance with the license agreement. This policy applies not only to individual desktop computers and laptops but to local/wide area networks as well.
Employees learning of any misuse of software or related documentation within the Company shall notify a member of management. Employees who reproduce, acquire, or use unauthorized copies of computer software will be subject to discipline, up to and including termination.

NETWORK SECURITY POLICY

As a user of the network, you may be allowed to access other networks (and/or the computer systems attached to those networks).

Therefore:
- Use of systems and/or networks in attempts to gain unauthorized access to remote systems is prohibited.
- Use of systems and/or networks to connect to other systems, in evasion of the physical limitations of the remote system/local, is prohibited.
- Decryption of System or User passwords is prohibited.
- The copying of System files is prohibited.
- Attempts to circumvent the protective mechanisms of any Company System are prohibited. Deliberate attempts to degrade system performance or capability, or attempts to damage systems, software or intellectual property of others are prohibited.
- Unauthorized downloading and/or installation of software without express permission is prohibited.
- The unauthorized publishing of copyrighted material on a Company server is prohibited and users are responsible for the consequences of such unauthorized use.
Virtually all commercial software is protected by the Federal Copyright Act. Use of Company facilities for the use of or the copying of computer software that does not contain specific permission to copy (some licenses do allow the making of one copy for backup) is prohibited.

WORKING CONDITIONS

RESPECT FOR BASIC HUMAN RIGHTS

Italin Group is committed to respect and protect all rights of our employees, customers, contractors, suppliers and stakeholders. We believe we are all equally entitled to our human rights without discrimination.
We respect and protect basic human rights guaranteed by international declarations as well as national constitutions and judicial precedents, and we do not infringe on such rights.
We respect one another as individuals and do not discriminate on the grounds of ethnicity or race; religious or political convictions or other beliefs; gender; regional or family background; disability; or age
We do not speak or act in ways that degrade individual dignity based on issues such as gender, authority or position (sexual harassment or power harassment), nor do we engage in any other form of harassment.
We will respect, protect and promote human rights. It is essential in sustaining a better work environment and enhancing global productivity

COLLECTIVE BARGAINING/FREEDOM TO ASSEMBLE

All employees shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment. Employees shall have the right to associate freely, to join, or not to join, trade unions or similar external representative organizations and to bargain collectively in accordance with local laws.

WAGES AND BENEFITS

All employees of Italin Group shall be paid at least the minimum wage as required by local law. In addition, all employees will be provided with legally mandated benefits. Wages will be paid at regular intervals and directly to employees. These wage payments will not be delayed, deferred, or withheld. Only authorized deductions will be permitted and will only be taken with the full consent and understanding of employees. Italin Group will provide clear and transparent information with regard to hours worked, pay rates, and authorized deductions. Wage deductions will not be used as disciplinary action or to keep employees tied to the employer or their jobs. Employees will not be held in debt bondage or forced to work in order to pay off a debt to the employer.

ENVIRONMENTAL STANDARDS

We improve the environment in which we live and work. In our work environment, we show respect for each other’s opinions, feelings and experience, which improves the well-being and safety of our customers, colleagues and business partners. We engage in philanthropic activities that strengthen our communities and we minimize our environmental footprint. We prevent pollution, promote the reduction of waste through reuse and recycling of waste we generate, and we practice and promote safe work practices. We measure and communicate the environmental, health and safety impact of our processes and continuously improve these to meet and exceed relating legislation and requirements. We will share information on sustainability with external stakeholders.